4.A.70 Student File Management

Business Administration 



Administrative Procedure: Student File Management



March 24, 2004
















Policy Reference



Legal Reference






The student file is a record or collection of records respecting student attendance, academic
achievement, and other related matters in the possession or control of the Board. These records may include:


  • Personal Information
  • Youth Criminal Justice Act (YCJA)
  • Third Party Information


The purpose of collecting this information shall relate to the provision of educational programs and services supporting the educational progress of the student.  Information may be collected either directly from the student or parent/guardian, or indirectly from another source.  Both collections are allowed under PHIA and FIPPA, although indirect collection requires consent, except under certain limited conditions. (See FIPPA subsections 37 (1) or 14 (2) of PHIA).


The student file shall be organized and separated into the cumulative file and the student support file.  Both are considered part of the student file for definition, collection, access, retention, and destruction or transfer considerations.


YCJA file shall be considered a separate entity with its management, transfer, and/or destruction governed by the YCJA.


Cumulative File (all students)


  • Standard or routine information that schools maintain for all students includes: 
  • The name of the student, gender, and date of birth
    • Manitoba Education identification number
    • Personal Health Identification Number (PHIN)
    • Any individualized health care plan or an emergency response plan applicable to the student
    • Name, address, and phone number of the parent/legal guardian of the student
    • School attendance, eligibility/citizenship status
    • School division of the student if the student is not a resident of the attending school
    • Any enrolment at other schools
    • Attendance records
    • A summary of the academic progress of the student, including the results of the mandatory standards examinations conducted on behalf of the Province of Manitoba


  • Information on any serious student misconduct, including suspension or expulsion.
  • Copy of any separation agreement or court order regarding child custody.
  • Student data tracking sheet identifying the location of all information about a student that is held by the Division.

Student Support File (some students)


  • Information about a student (may be held in more than one location - see Student Data Tracking sheet)
  • Documentation about the provision of resource services from within or outside of the school division/district
  • Ongoing health information
  • School clinician referrals and reports, with exceptions of psychology and social work
  • Up to date notations or referrals or contacts with external agencies
  • Results of specialized diagnostic tests deemed necessary by the school team
  • Service provider reports
  • Individualized Education Plan
  • Behaviour Plans
  • Low incidence funding applications


Youth Criminal Justice Act (some students)


  • Access, disclosure, retention, and destruction is set out in the Youth Criminal Justice Act (Canada).

Management Requirement (YCJA)


  • Strict security is required (must be kept separate from cumulative and student support files).
  • School principal acts as the custodian of the YCJA file.
  • A list of authorized persons who can access this file shall be attached to it.
  • This file shall be destroyed when no longer applicable or student leaves the school.
  • When the student leaves school, the principal shall contact the police or probation officer.


Student File Review Procedures


The following procedures apply to an annual review and culling of student files:


  • Student files and working files are to be reviewed annually by each classroom teacher and the resource teacher(s) before the end of the school year.
  • The files shall be reviewed for
    • Insert updates.
    • Accuracy of student data tracking sheet.


Responsibility for Culling Procedures


The principal, in consultation with staff, will cull the cumulative file and support file annually, reviewing:


  • Clinician and specialist reports
  • Young Offender information.
  • Psychological assessments and social work reports will not be held in either the cumulative file or support file.  The existence of such assessments will be noted in the student data-tracking sheet.


When any part of a student file is no longer required, or the authorized retention period has expired, destruction of the information from the student file shall be listed for content and sent to the Divisional Records Manager for destruction.  A copy of the records content shall be sent with the records to be destroyed.  The summary will be kept on file as part of the disposition system.


Access and Privacy


Staff access to files is permitted to the extent the information is necessary to assist in the educational program of the student.  Various staff members may need to have access to different pieces of information in order to carry out their duties.


Access to information in the Youth Criminal Justice file may only be made available under restricted conditions:


  • To ensure compliance by the student with a court order
  • To ensure safety of staff, students, or other persons


A list of those entitled to access shall be attached to the Youth Criminal Justice file.


Students who have reached the age of majority (18) may have access to their files, both personal and health information.  However schools are not authorized to disclose information in the YCJA file to the student or to parent/guardian.


Parents/guardians can access the student file until the child reaches the age of majority, except under certain conditions. These conditions for both students over the age of 18 or parents of students under the age of 18 are that the:


  • Disclosure could reasonably be expected to constitute an unreasonable invasion of the privacy of a third party.
  • Disclosure could reasonably be expected to be detrimental to the education of the student.
  • Disclosure could reasonably be expected to cause serious physical or emotional harm to the student or another person.
  • Disclosure could reasonably be expected to be injurious to the enforcement of an enactment or the conduct of an investigation under an enactment.


Divorced/separated parents have the right to receive information as to the health and education of their child unless the court orders otherwise.


Third party requests for information may be granted if the disclosure is for the purpose for which the information was compiled or collected (e.g., educational programming) as outline under FIPPA or PHIA.  Consent of the student (over 18) or parent/guardian shall be obtained.


For further information on Access and Privacy guidelines see pages 13-20 of the

Manitoba Student File Guidelines.


Access to this information shall be supervised by school personnel to maintain the integrity of the file.  The files shall not leave the school building.  Photocopies of documents can be released to parents/guardians.


Third Party Requests for Personal Information or Personal Health Information


A third party is a person, group of persons, or an organization other than the school division.  School staff may receive requests for personal information or personal health information about a student or former student.


The Division and the Access and Privacy Coordinator shall handle all third party requests for access to the personal information and personal health information of an individual within the organization.  They shall ensure that:


  • Disclosure is authorized under FIPPA-PHIA.
  • Disclosure of personal information and personal health information is limited to the amount necessary to accomplish the authorized purpose.


Student File Transfer Procedures


  • For transfers within the Division, the student file is forwarded to the receiving school.
  • Written parent/guardian permission is required to transfer each of the components of the student file to an out-of-division school.
  • When student files are transferred to another division, they shall be reviewed to ensure that only the personal information and personal health information necessary for the provision of educational services to that student is forwarded.  The student cumulative files described in these procedures, will be passed on to the requesting educational authority, with the exception of the following:
    • Personal notes of the resource teacher, counselor, clinician, or administrator
    • Meeting notes that are not necessary for the continued educational services for that student
    • Information about a third party
    • Other agency information that does not pertain to schooling and provision of educational services


Cumulative and Student Support file – Retention


  • Except for Senior 1-4 marks, information in the student file should be retained for a minimum of ten years after the student ceases to attend school or until the file is transferred to another school.
  • Senior 1-4 marks should be retained for thirty years.


Cumulative and Student Support File – Destruction


  • Destruction must be carried out in a manner that protects the privacy of the student.
  • Where personal health information is destroyed, the principal will record the name of the individual whose personal health information is destroyed, the time period to which the information relates, the method of destruction, and the person responsible for supervising the destruction.
  • The file will be forwarded to the Divisional Records Manager for destruction.
  • The record of destruction will be forwarded to the Divisional Records Manager for archival reference.


Youth Criminal Justice File – Retention and Destruction


The YCJ File must be destroyed when it is no longer required for the purpose for which it was established.


If the student transfers to another school division or district, the file must be destroyed.


(The Need to Know Document – The Guide for Timely and Ongoing Information Sharing Between School Officials & Justice System Personnel with the Youth Justice Act – 2003 Edition)